FCPAméricas Blog
Archive for Howard Sklar category:
The FCPA, Iran Sanctions, and Compliance Convergence
10.18.2012
My friends Howard Sklar and Tom Fox are fond of talking about “compliance convergence.” The idea is that, in an age where compliance expectations are created by a wide range of legal regimes – everything from anti-corruption to export controls, anti-trust to environmental laws – companies can structure their compliance mechanisms efficiently to address a […]
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Third Party Red Flags and Latin America
1.03.2012
Looking back at FCPA enforcement actions in 2011 that involved Latin America, all but one included risk created “indirectly” by third parties. And that one, Tyson Foods, involved payments to spouses of Mexican officials, a potentially odd twist on the concept of “third party risk.” The kind of third parties used in these cases included […]
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Going Beyond the TI Index: New tools for assessing integrity risks
12.01.2011
Enforcement officials and “best practice” descriptions stress that adequate anti-corruption compliance programs are based in sound corruption risk assessments. Howard Sklar recently provided an in-depth look at how risk assessments can be used for maximum effect. The question remains, however: how should compliance officers assess the integrity risks presented by particular countries or industries? Historically, […]